On July 9, 2025, the California Air Resources Board (CARB) released a set of Frequently Asked Questions related to regulatory development and initial reporting obligations under SB 253 and SB 261. While this FAQ does not carry the force of law, it offers helpful insights for companies preparing for upcoming compliance deadlines—in particular, the January 1, 2026 deadline for initial climate-related financial risk reports under SB 261. This guidance is especially timely given CARB's delay in finalizing the implementing regulations, which were required to be adopted by July 1, 2025.
Key Takeaways for Initial SB 261 Reporting:
1. How should the SB 261 report be
published?
CARB will create a public docket on December 1, 2025, where covered
entities can post the URL linking to their climate-related
financial risk report.
This docket will remain open through July 1, 2026, serving as a
centralized location for public access to all submitted
reports.
2. What time period should the report
cover?
Recognizing that climate-related data is typically collected on a
fiscal year basis—and that preparing such reports takes
time—CARB has indicated that initial SB 261 reports due by
January 1, 2026, may cover either FY 2023–2024 or FY
2024–2025, depending on the company's reporting
cycle.
3. Future rulemaking is still to come:
CARB notes that this guidance applies only to the inaugural
reports, and that future implementing regulations may impose
additional or modified requirements, consistent with the statutory
framework of SB 261.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
